of slaves. R v Hodge In 1811, Arthur Hodge became the first (and only) British subject ever to stand trial for the murder of a slave. As part of his defence, Hodge argued that "A Negro being property, it was no greater offense for his master to kill him than it would be to kill his dog," but the court did not accept the submission, and point was dismissed summarily. Counsel for the prosecution also obliquely referred to the Amelioration Act 1798 passed by the Legislature of the Leeward Islands, which applied in the British Virgin Islands. That Act provided for penalties for slave owners who inflicted cruel or unusual punishments on their slaves, but it only provides for fines, and does not expressly indicate that a slave owner could be guilty of a greater crime such as murder or another offence against the person. The trial took place under English common law in British Virgin Islands. However, there was no appeal (Hodge was executed a mere eight days after the jury handed down their verdict). The jury (composed largely of slave owners) actually recommended mercy, but the court nonetheless sentenced Hodge to death, and so the directions of the trial judge are not treated by commentators as an authoritative precedent. Forbes v Cochrane Confirmation of the Mansfield ruling, that "positive law" would be required to make slavery lawful, appears in the judgment of Mr. Justice Best in Forbes v Cochrane in 1824. He said, "There is no statute recognising slavery which operates in that part of the British empire in which we are now called upon to administer justice." He described the Somerset case as entitling a slave in England to discharge (from that status), and rendering any person attempting to force him back into slavery as guilty of trespass. But not all reports of the case agree. Subsequent legislation The common law, ultimately, would go no further. But the decision of 1772 in James Somersett's case was widely interpreted as making slavery illegal. Whilst some academics have disupted this, the perception was fuelled by the growing abolitionist movement, notwithstanding this was scarcely an accurate reflection of the decision. Slavery did not, like villeinage, die naturally from adverse public opinion, because vested mercantile interests were too valuable. In 1788 the Slave Trade Act 1788 was passed, partly in response to the Zong Massacre to ameliorate the conditions under which